Deemed Registration Under RERA: When Silence Registers a Project, and What Buyers Check
Section 5 of the RERA Act gives the Authority 30 days to grant or reject a project registration; if it does neither, the project is deemed registered. This guide explains deemed registration, validity under Section 5(3), extensions under Section 6, and a seven-step registration check for Bengaluru buyers.
A promoter files an application to register a housing project with the state's real estate regulator. Thirty days pass. The Authority neither grants the registration nor rejects it. What happens next is written into Section 5(2) of the Real Estate (Regulation and Development) Act, 2016: the project is deemed to have been registered, and within seven more days the Authority must issue a registration number and login details so the promoter can create the project's web page. For a Bengaluru buyer, a project that reached registration this way can look the same on a brochure as any other. Understanding the route helps you ask the right questions.
This guide reads Sections 5 and 6 from the Gazette copy of the Act and explains what deemed registration means, what it does not mean, and how a buyer should verify a project either way.
The short answer. Section 5(1) gives the Authority thirty days from receiving an application to either grant registration with a registration number and login, or reject it for reasons recorded in writing after giving the applicant a hearing. Under Section 5(2), if it does neither, the project is deemed registered and a number and login must be provided within seven days after that period. Section 5(3) says the registration is valid for the completion period the promoter declared, and Section 6 allows extension for force majeure and, in reasonable circumstances, up to one year in aggregate. The trade-off: deemed registration keeps projects from being stuck on official delay, but it means the registration may not rest on a written grant order, so your own document checks matter more.
What does Section 5 require the Authority to do?
Section 5(1) says that on receipt of an application under Section 4(1), the Authority shall, within a period of thirty days, either grant registration subject to the Act, rules and regulations and provide a registration number, including a login ID and password for the promoter to access the Authority's website and create a web page for the project; or reject the application for reasons to be recorded in writing if it does not conform to the Act, rules or regulations.
The proviso adds a safeguard for promoters: no application shall be rejected unless the applicant has been given an opportunity of being heard. So the Act expects one of two written outcomes within thirty days, and a hearing before any rejection.
| Provision | What the Act says | What it means for a buyer |
|---|---|---|
| Section 5(1)(a) | Grant within 30 days, with registration number and login | The usual route to a registered project |
| Section 5(1)(b) | Reject for reasons in writing, after a hearing | A rejected project cannot lawfully be marketed |
| Section 5(2) | If neither, project deemed registered; number and login within 7 days | Registration can arise from the Authority's silence |
| Section 5(3) | Valid for the completion period declared by the promoter | The validity date is the promoter's own commitment |
| Section 6 | Extension for force majeure, or up to one year in aggregate in reasonable circumstances | Validity can be extended, within limits |
What exactly is deemed registration?
Section 5(2) states that if the Authority fails to grant the registration or reject the application as provided in sub-section (1), the project shall be deemed to have been registered, and the Authority shall, within seven days of the expiry of the thirty day period, provide a registration number and a login ID and password to the promoter for accessing the Authority's website and creating the project's web page.
The FAQ published by the Telangana regulator reads the provision the same way, answering yes to the question whether registration not given within 30 days will be deemed registration, where the Authority fails to issue any communication about deficiencies within 30 days of receiving the application. That FAQ is one regulator's guidance; the statutory text in Section 5(2) is the same in every state.
Are a deemed registered project's obligations any lighter?
Nothing in Section 5 says so. Section 11(1) of the Act expressly refers to a promoter receiving login details either under clause (a) of Section 5(1) or under Section 5(2), and in both cases requires the promoter to create a web page on the Authority's website and enter all details of the project as required under Section 4(2), for public viewing. That includes quarterly updates of bookings, garages, approvals taken and pending, and project status.
The declarations in Section 4(2) are also the same, because they are part of the application itself, whichever way registration follows. Those include the declaration on the time period for completion and the 70 percent separate account, which PropNewz explained in our guide to the separate account.
How long does registration last, deemed or not?
Section 5(3) says registration granted under Section 5 shall be valid for the period declared by the promoter under sub-clause (C) of clause (l) of Section 4(2) for completion of the project or phase. In other words, the promoter's own declared completion date sets the validity.
Section 6 then allows extension. The Authority may extend registration on the promoter's application due to force majeure, which the Act defines as war, flood, drought, fire, cyclone, earthquake or any other calamity caused by nature affecting regular development of the project. A proviso also allows the Authority, in reasonable circumstances, without default by the promoter and for reasons recorded in writing, to extend registration for such time as it considers necessary, not exceeding one year in aggregate. No extension application can be rejected without a hearing. PropNewz looked at what happens around the end of validity in our guide to booking late in a project's registration.
How should a Bengaluru buyer check a project's registration?
Start on the regulator's website, not the brochure or a sales presentation, however polished. Search the registration number, confirm the project and promoter names, and read the declared completion date, since Section 5(3) ties validity to it. Then read the web page the promoter is required to maintain under Section 11(1), including the latest quarterly update. If the registration appears to have been deemed, the obligations described above still apply, so check the same documents with the same care.
Whether the project is a large phased township or a smaller development, such as projects listed on PropNewz like Prestige Lavender Fields at Gunjur, confirm that the specific phase you are buying is the one registered, because the Act treats every phase as a standalone project.
- Search the registration number on the state regulator's website.
- Match project name, promoter and phase with the brochure.
- Note the declared completion date and registration validity.
- Check whether any extension has been granted and why.
- Read the latest quarterly update on bookings and approvals.
- Ask the promoter for copies of key approvals listed.
- Keep dated screenshots of every page you rely on.
What should you ask the promoter if the registration was deemed?
Ask the same questions you would ask about any project, but ask for the paper behind each answer. Request copies of the approvals listed in the registration filing, the sanctioned plans, and the declaration on the completion period. Ask whether the regulator later raised any deficiency with the application and, if so, how it was resolved. Ask for the account details into which your payments will go under the 70 percent rule. And ask for the latest quarterly update the promoter has uploaded under Section 11(1).
A promoter of a properly run project should be able to answer each of these in writing within a few days. Slow or evasive answers are worth noting, whatever route the registration took. Conversely, clear answers and consistent documents are useful reassurance, again whatever route the registration took. The point is not to treat deemed registration as a red flag, but to remember that the registration itself is a starting point for your checks, not their end. If anything you are told does not match what the regulator's website shows, rely on the website and the documents, and raise the gap with the promoter before paying.
What does deemed registration not tell you?
It does not tell you how closely the application was examined. Section 5(2) is triggered by the Authority's failure to decide within thirty days, not by any finding. That is not a reason to distrust a project in itself, and a regular grant is not a guarantee either. But it is a reason to rely on documents rather than on the fact of registration alone. PropNewz's Section 4(2) filing checklist lists the documents a promoter must file, which are the ones worth reading whichever route led to registration.
It also does not change the rule against marketing before registration. Section 3(1) bars a promoter from advertising, marketing, booking or selling in a project in a planning area without registering it. Until a registration number exists, whether by grant or by deeming, the Act does not permit sales.
Frequently asked questions
What is deemed registration under RERA?
Under Section 5(2) of the Real Estate (Regulation and Development) Act, 2016, if the Authority neither grants nor rejects a registration application within thirty days, the project is deemed registered, and the Authority must provide a registration number and login within seven days after that period.
Can a RERA authority reject a project without hearing the promoter?
No. The proviso to Section 5(1) says no application shall be rejected unless the applicant has been given an opportunity of being heard, and any rejection must be for reasons recorded in writing where the application does not conform to the Act, rules or regulations.
How long is a RERA project registration valid?
Section 5(3) says registration is valid for the period the promoter declared for completing the project or phase under Section 4(2)(l)(C). Section 6 allows extension for force majeure and, in reasonable circumstances, up to one year in aggregate, for reasons recorded in writing.
Does a deemed registered promoter have the same duties?
Yes. Section 11(1) applies whether login details were issued under Section 5(1)(a) or under Section 5(2), requiring the promoter to create the project web page and keep bookings, approvals and project status updated every quarter for public viewing on the Authority's website.
Last updated 2026-10-31. PropNewz Team.
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